THE ACIT, CIRCLE-2(1)(1), AHMEDABAD vs. M/S. INTAS PHARMACEUTICALS LTD., AHMEDABAD

Accordingly, this ground raised by the Revenue is dismissed

Bench: S/Shri T.R. Senthil Kumar & Makarand V.Mahadeokarasstt.Year : 2015-16 Acit, Cir.2(1)(1) M/S.Intas Pharmaceuticals Ltd Vejalpur Vs Corporate House Ahmedabad. S.G. Highway Nr.Sola Bridge, Thaltej Ahmedabad 380 054. Pan : Aaaci 5120 L Asstt.Year : 2015-16 M/S.Intas Pharmaceuticals Ltd Acit, Cir.2(1)(1) Corporate House Vs Vejalpur S.G. Highway Ahmedabad. Nr.Sola Bridge, Thaltej Ahmedabad 380 054. Pan : Aaaci 5120 L (Applicant) (Responent) : Assessee By Shri S.N. Soparkar, Sr.Advocae & Shri Parin Shah, Ar : Shri Ragnesh Das, Cit-Dr Revenue By सुनवाई क" तारीख/Date Of Hearing : 28/04/2025 घोषणा क" तारीख /Date Of Pronouncement: 21/05/2025 आदेश आदेश/O R D E R आदेश आदेश

68,91,720 Proportionate Interest Disallowance (B × C) ÷ A Amount Disallowed u/s 36(1)(iii) Rs. 11,29,21,996 ITA No.281 and 222/Ahd/2021 43 80. Before the CIT(A), the assessee submitted that the disallowance was unjustified and that it had substantial interest-free funds available throughout the year, far in excess of the average CWIP balance

ANISHA R DHANANI,MUMBAI vs. THE ACIT, CIRCLE-1(1)(2), VADODARA

In the result the appeal filed by the assessee is allowed

Bench: Ms Suchitra Kamble & Shri Waseem Ahmedआयकर अपील सं./Ita No. 406/Ahd/2020 िनधा"रण वष"/Asstt. Year:2005-2006 Anisha R. Dhanani, A.C.I.T., 281, 28Th Floor, Vs. Circle-1(1)(2) Kalpatru Heights, Vadodara. Dr. A.R. Nair Road, Agripada, Mumbai-400011. Pan: Actpd3111C

section 68 on the reasoning that there was not sufficient capacity/creditworthiness of her father to justify the disbursement of such amount in cash and jewelry. 39. However the AO disregarded the explanation furnished by the assessee by observing as under: 3. I have carefully considered the assessee’s reply, but the same is not found tenable. At the time

RAOOF R DHANANI,MUMBAI vs. THE ACIT, CIRCLE-1(1)(2), VADODARA

In the result the appeal filed by the assessee is allowed

Bench: Ms Suchitra Kamble & Shri Waseem Ahmedआयकर अपील सं./Ita No. 406/Ahd/2020 िनधा"रण वष"/Asstt. Year:2005-2006 Anisha R. Dhanani, A.C.I.T., 281, 28Th Floor, Vs. Circle-1(1)(2) Kalpatru Heights, Vadodara. Dr. A.R. Nair Road, Agripada, Mumbai-400011. Pan: Actpd3111C

section 68 on the reasoning that there was not sufficient capacity/creditworthiness of her father to justify the disbursement of such amount in cash and jewelry. 39. However the AO disregarded the explanation furnished by the assessee by observing as under: 3. I have carefully considered the assessee’s reply, but the same is not found tenable. At the time

RAOOF R DHANANI,MUMBAI vs. THE ACIT, CIRCLE-1(1)(2), VADODARA

In the result the appeal filed by the assessee is allowed

Bench: Ms Suchitra Kamble & Shri Waseem Ahmedआयकर अपील सं./Ita No. 406/Ahd/2020 िनधा"रण वष"/Asstt. Year:2005-2006 Anisha R. Dhanani, A.C.I.T., 281, 28Th Floor, Vs. Circle-1(1)(2) Kalpatru Heights, Vadodara. Dr. A.R. Nair Road, Agripada, Mumbai-400011. Pan: Actpd3111C

section 68 on the reasoning that there was not sufficient capacity/creditworthiness of her father to justify the disbursement of such amount in cash and jewelry. 39. However the AO disregarded the explanation furnished by the assessee by observing as under: 3. I have carefully considered the assessee’s reply, but the same is not found tenable. At the time

RAOOF R DHANANI,MUMBAI vs. THE ACIT CIRCLE-1(1)(2), VADODARA

In the result the appeal filed by the assessee is allowed

Bench: Ms Suchitra Kamble & Shri Waseem Ahmedआयकर अपील सं./Ita No. 406/Ahd/2020 िनधा"रण वष"/Asstt. Year:2005-2006 Anisha R. Dhanani, A.C.I.T., 281, 28Th Floor, Vs. Circle-1(1)(2) Kalpatru Heights, Vadodara. Dr. A.R. Nair Road, Agripada, Mumbai-400011. Pan: Actpd3111C

section 68 on the reasoning that there was not sufficient capacity/creditworthiness of her father to justify the disbursement of such amount in cash and jewelry. 39. However the AO disregarded the explanation furnished by the assessee by observing as under: 3. I have carefully considered the assessee’s reply, but the same is not found tenable. At the time

M/S. SHELL INTERNATIONAL B.V.,,MUMBAI vs. THE DY. CIT, INTL. TAXN.-1,, AHMEDABAD

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

68. Under HRIT - System Administration Services, the assessee charges fee associated with Learning systems like Learning Management System, Learning projects like Competence Management, business process enhancements etc. The argument of the assessee is that this fee is charged to group companies using learning infrastructure via a learning infrastructure fee per head. This fee is in relation to recovery of cost

SHELL INTERNATIONAL B.V., ,AHMEDABAD vs. THE ACIT, INTL. TAXN.-1, AHMEDABAD

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

68. Under HRIT - System Administration Services, the assessee charges fee associated with Learning systems like Learning Management System, Learning projects like Competence Management, business process enhancements etc. The argument of the assessee is that this fee is charged to group companies using learning infrastructure via a learning infrastructure fee per head. This fee is in relation to recovery of cost

M/S. SHELL INTERNATIONAL B.V.,,MUMBAI vs. THE DY. CIT, INTL. TAXN.-1,, AHMEDABAD

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

68. Under HRIT - System Administration Services, the assessee charges fee associated with Learning systems like Learning Management System, Learning projects like Competence Management, business process enhancements etc. The argument of the assessee is that this fee is charged to group companies using learning infrastructure via a learning infrastructure fee per head. This fee is in relation to recovery of cost

M/S. SHELL INTERNATIONAL B.V.,MUMBAI vs. THE ACIT, INTL. TAXN.-2, AHMEDABAD

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

68. Under HRIT - System Administration Services, the assessee charges fee associated with Learning systems like Learning Management System, Learning projects like Competence Management, business process enhancements etc. The argument of the assessee is that this fee is charged to group companies using learning infrastructure via a learning infrastructure fee per head. This fee is in relation to recovery of cost

SHELL INTERNATIONAL B.V., ,MUMBAI vs. THE ACIT, INTL. TAXN.-1,, AHMEDABAD

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

68. Under HRIT - System Administration Services, the assessee charges fee associated with Learning systems like Learning Management System, Learning projects like Competence Management, business process enhancements etc. The argument of the assessee is that this fee is charged to group companies using learning infrastructure via a learning infrastructure fee per head. This fee is in relation to recovery of cost

M/S. SHELL INTERNATIONAL B.V.,,MUMBAI vs. THE DY. CIT, INTL. TAXN.-1,, AHMEDABAD

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

68. Under HRIT - System Administration Services, the assessee charges fee associated with Learning systems like Learning Management System, Learning projects like Competence Management, business process enhancements etc. The argument of the assessee is that this fee is charged to group companies using learning infrastructure via a learning infrastructure fee per head. This fee is in relation to recovery of cost

SHELL INTERNATIONAL B.V., ,MUMBAI vs. THE ACIT, INTL. TAXN.-1,, AHMEDABAD

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

68. Under HRIT - System Administration Services, the assessee charges fee associated with Learning systems like Learning Management System, Learning projects like Competence Management, business process enhancements etc. The argument of the assessee is that this fee is charged to group companies using learning infrastructure via a learning infrastructure fee per head. This fee is in relation to recovery of cost

M/S. SHELL INTERNATIONAL B.V., ,MUMBAI vs. THE DY. CIT, INTL. TAXN.-1,, AHMEDABAD

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

68. Under HRIT - System Administration Services, the assessee charges fee associated with Learning systems like Learning Management System, Learning projects like Competence Management, business process enhancements etc. The argument of the assessee is that this fee is charged to group companies using learning infrastructure via a learning infrastructure fee per head. This fee is in relation to recovery of cost

SHELL INTERNATIONAL B.V., ,MUMBAI vs. THE ACIT, INTL. TAXN.-2, AHMEDABAD

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

68. Under HRIT - System Administration Services, the assessee charges fee associated with Learning systems like Learning Management System, Learning projects like Competence Management, business process enhancements etc. The argument of the assessee is that this fee is charged to group companies using learning infrastructure via a learning infrastructure fee per head. This fee is in relation to recovery of cost

SHELL INTERNATIONAL B.V.,MUMBAI vs. THE ACIT, INT.TAXA.-2, AHMEDABAD

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

68. Under HRIT - System Administration Services, the assessee charges fee associated with Learning systems like Learning Management System, Learning projects like Competence Management, business process enhancements etc. The argument of the assessee is that this fee is charged to group companies using learning infrastructure via a learning infrastructure fee per head. This fee is in relation to recovery of cost

DCIT CIRCLE-3(3), AHMEDABAD vs. SHRI ALPESHKUMAR C.PATEL, AHMEDABAD

In the result, the appeal of the assessee is partly allowed

Bench: Shri Waseem Ahmed & Shri T.R. Senthil Kumarआयकर अपील सं./Ita No. 1908/Ahd/2018 िनधा"रण वष"/Asstt. Year: 2011-2012 Alpeshkumar C. Patel, A.C.I.T., 503, Milestone Building, Vs. Circle-3(3), Drive In Road, Ahmedabad. Thaltej, Ahmedabad-380052. Pan: Aeapp9489G

221 Taxmann 143 (Guj.) as the appellant was not required to reflect such entries in his books of account. Further, on perusal of the assessment order, I find that the AO has not suspected or questioned the transaction with the confirming party on the ground of adequacy/inadequacy of consideration but has merely doubted the genuineness of the payment made solely

HARISHKUMAR KHUSHALRAY BHATT,AHMEDABAD vs. THE ITO, WARD-3(3)(2) NOW WARD-3(3)(1), AHMEDABAD

In the result the appeal of the assessee is partly allowed for statistical purposes

Bench: S/Shri T.R. Senthil Kumar & Makarand V.Mahadeokarasstt.Year : 2017-18 Harishkumar Khushalray Bhatt Ito, Ward-3(3)(2) P/1, Chandragupta Apartment Vs. Ahmedabad. Nr. Gordhandas Patel Hospital Vastrapur Ahmedabad. Pan : Abspb 3786 F (Applicant) (Responent) Assessee By : Shri Pritesh L. Shah, Ar : Shri Uday Kishanrao Kakne, Sr.Dr Revenue By सुनवाई क" तारीख/Date Of Hearing : 07/07/2025 घोषणा क" तारीख /Date Of Pronouncement: 15/07/2025 आदेश/O R D E R आदेश आदेश आदेश

1. The learned CIT(A) erred in law and on facts in confirming the addition made by AO of Rs.32,61,500/- being the amount of Cash deposited to the Bank Under Section 69A of the Income Tax Act, 1961, such addition is requested to be deleted. 2. The learned CIT(A) erred in law and on facts

SHREE RAMA MULTI-TECH LTD.,,AHMEDABAD vs. THE DY.CIT.,CRCLE-8,, AHMEDABAD

In the result, appeal of the assessee is partly allowed

Bench: Shri Rajpal Yadav & Shri Waseem Ahmed

68. However, the Ld. CIT-A confirmed the order of the AO by observing as under:- “10.2 I have carefully considered the submissions made by the appellant and the argument taken by the assessing officer in the light of material available on records. It is the case of the appellant, as evident from an additional submission filed, that

SHREE RAMA MULTI-TECH LTD.,,AHMEDABAD vs. THE ACIT(OSD) CIRCLE-8, AHMEDABAD

In the result, appeal of the assessee is partly allowed

Bench: Shri Rajpal Yadav & Shri Waseem Ahmed

68. However, the Ld. CIT-A confirmed the order of the AO by observing as under:- “10.2 I have carefully considered the submissions made by the appellant and the argument taken by the assessing officer in the light of material available on records. It is the case of the appellant, as evident from an additional submission filed, that